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SMITH v. COMMISSIONER

Docket No. 28315.

10 T.C.M. 1124 (1951)

Cornelius M. Smith v. Commissioner.

United States Tax Court.

Entered November 30, 1951.

Attorney(s) appearing for the Case

Richard P. Jackson, Esq., and William B. Van Buren, Esq., for the petitioner. Michael Waris, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner has determined a deficiency in petitioner's income tax for the year 1946 of $66,140.03.

The deficiency arises by virtue of an addition by respondent of $83,049.45 to the partnership income reported by petitioner. The net income of the partnership was reported on individual tax returns of petitioner and his two sons in the following amounts:

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